88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac… IRCProposed Rules (FR)Proposed Jul 12, 2023
…C.-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insurance.
IRCCode / StatuteJan 24, 2020related by meaning
(c)(1)(D) (D) Public inspection of applications for exemption and notice of status In the case of a failure to comply with the requirements of section 6104(d) with respect to any exempt status application materials (as defined in such section) or notice materials (as defined in such section) on the date and in the mann…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…
See
Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/05/03/provider-charges-relative-to-medicare-rates-2012-2018/.
Back to Citation
210…
IRCCourt RulingsDec 19, 2000
…ot contain any adjustments related to Catamount
and did not assert an addition to tax under section 6659 with
respect to Catamount. Petitioners timely petitioned this Court
to redetermine the determinations reflected in the 1984 notice,
see Toan v. Commissioner
, docket No. 26011-84 (Toans’ individual
case), and the Co…
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026
…rtain information addressed in this notice will be subject to the Paperwork Reduction Act (PRA), 44 USC 3507. No collection of information will be required until approved by the Office of Management and Budget (OMB) under the PRA.
IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
… HHS and Transportation ability to conduct these analyses.
E. Regulatory Flexibility Act The RFA (5 USC 601, et seq.), requires agencies to prepare an initial regulatory flexibility analysis to describe the impact of these proposed rules on small entities, unless the head of the agency can certify that the rule will no…
IRCCourt RulingsDec 11, 2003related by meaning
bchapter B of chapter 63 (relating to
deficiency procedures for income, estate, gift, and certain
excise taxes), subsection (a) shall not apply to any addition to tax under section 6651, 6654, 6655; except that
it shall apply–
(continued...)
“predictable escape from any possible penalty liability” that
would have been …
IRCCourt RulingsFeb 25, 2016related by meaning
ed for Forms 5329. Petitioner once again does not argue that his
- 38 -
[*38] failure to timely pay was due to reasonable cause and not due to willful neglect. Accordingly, petitioner is liable for the addition to tax under section
6651(a)(2) for 2004 and 2005.
VII. Section 6662A Penalty
Section 6662A provides: "If a t…
IRCCourt RulingsSep 15, 2005related by meaning
aph, the
maximum penalty under this subparagraph shall not
exöeed $50,000. [Emphasis added.]
As is clear from the above-emphasized language, a section 6651(a)(2) addition to tax is directly tied to the amount of tax
due. On the other hand, a section 6652(c)(1) penalty is not tied
to the amount of tax due, but instead i…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…dual retirement annuity described in section 408(b).
6 The definition of “State” for purposes of 42 USC 1395x(r)(1) is in 42 USC 410(h), which provides that the term “State” includes the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and American Samoa.
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
er 1 as determined under subsection (e)
by substituting —
(i) in paragraph (1)(A), “200 percent”
for “150 percent” . . . .
2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which
all accuracy-related penalties are imposed on underpayments of tax.
Section 6662(b) lists the penalizab…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
IRCCourt RulingsOct 19, 2010related by meaning
section 6651(a) (1) and (2).
"The sec. 6651(a) (1) addition to tax is reduced by the
amount of the sec. 6651(a) (2) addition to tax for any month (or fraction thereof) to which an addition to tax applies under both
sec. 6651(a) (1) and (2). See sec. 6651(c) (1).
"We acknowledge that petitioner failed to assign any err…
IRCCourt RulingsFeb 9, 1998related by meaning
this case of most of the
enumerated badges of fraud. Accordingly, petitioner is liable
for section 6651(f) additions to tax for 1990, 1991, and 1992. Section 6654(a) imposes an addition to tax for failure to
make timely estimated income tax payments. Where prepayments of
tax do not equal the percentage of total liabil…
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
IRCCourt RulingsMar 9, 2011related by meaning
ds of thousands of dollars
in DISC commissions each year from a well-established business,
and a 25-percent share in a company receiving such a steady stream of income should have been worth a large amount.
-28IV. Section 6662(a) Penalty
Section 6662(a) and (b) (1) and (2) imposes an accuracyrelated penalty of 20 perce…
IRCCourt RulingsAug 24, 2000
…ficiency in petitioners' 1982 Federal income tax and additions
to tax under sections 6653(a)(1) and 6659
1
in the respective
amounts of $27,552, $1,377.60, and $8,265.60. Respondent also
determined that petitioners are liable for an addition to tax